10 i 12 1B 14 15 16 7 18 19 20 21 2 23 24 25 w JOHN P. HANNON IT SBNo: 111692 716 Capitola Avenue, Ste. F Capitola, CA 95010 PH: (831) 476-8005 FAX: (831) 476-8984 Attorney for Plaintiff: DAVID COMPTON FLED aT 4 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CRUZ DAVID COMPTON, ) casenceyA 69154 ) Plaintiff, ) PLAINTIFF DAVID COMPTON’S ) COMPLAINT FOR DAMAGES v. ) ) (Fraud; Breach of Contract] NARCONON VISTA BAY (abusiness ) entity form unknown); NARCONON ) INTERNATIONAL (@ California ) corporation); ASSOCIATION FOR ) LIVING AND EDUCATION ) INTERNATIONAL (a California ) corporation) and DOES | through 20, ) inclusive, ) ) Defendants. ) ee) FIRST CAUSE OF ACTION [Fraud and Deceit] 1, Plaintiff, David Compton, is a resident of the State of California. 2. Defendant, Narconon Vista Bay is a business entity operating in the County of Santa Cruz, State of California. Defendants, Narconon Internatonal and Association for Better ORIGINAL10 i 12 2B 14 15 16 17 18 19 20 21 2 23 24 25 Y 7 Living and Education International are corporations licensed under the laws of the State of California and, in doing the things hereinafter alleged, did said acts in the County of Santa Cruz, State of California, 3. Plaintiff is unaware of the true names and identities of those individuals named herein as Does 1 through 20, inclusive. At such time as Plaintiff becomes aware of the true names and identities of such fictitiously named Defendants, Plaintiff will pray leave of this court to amend this complaint accordingly. 4. Each of the Defendants named herein was the agent, employee or assign of the remaining Defendants, and, in doing the things hereinafter alleged did said acts within the course and scope of the agency, employment or assignment. 5. Plaintiffs the father of Lucas Compton. Lucas Compton suffers from addiction to drugs. 6. On of about January 23, 2010, Plaintiff contacted Defendants for purposes of providing services to help Lucas Compton to recover from his addiction process. 7. Prior to agreeing to pay for the services, Plaintiff was falsely informed as to certain facts or was not informed of facts which were material to Plaintiff's decision to retain Defendants. Among the various facts told to Plaintiff as well as the facts that Defendants should have told Plaintiff are the following: a. Plaintiff was not informed that Defendants are an off-shoot of the Church of Scientology and that the programs offered by Defendants are used as a recruiting tool for the Church of Scientology. b. Plaintiff was informed that Lucas Compton could immediately begin treatment, when, in fact, Defendants have engaged in and continue to engage in a “bait and switch” program whereby all or virtually all persons who go to Defendants facility are first referred to10 ul 12 13 14 15 16 17 18 19 20 2 2 23 24 25 v & “chemical detoxification” for which a separate charge is imposed. In fact, Lucas Compton was placed into chemical detoxification at a cost of an additional $6,500.00. ¢. Plaintiff was informed that Defendants utilize accepted standards of treatment for chemical dependency when, if fact, the treatment by Defendants is not accepted in the treatment community as being within the standard of care. 4, Plaintiff was informed that Defendants had a 70% success rate in treatment of drug dependency when, in fact, their success rate is much lower. ¢. Plaintiff was told or was lead to believe that the facilities were clean and sanitary, In fact, the withdrawal house was disgusting. The facility smelled of mold and the water dispenser had mold growing out of it. ‘The facility had 10 residents of which 8 men all shared the same bathroom. There were human feces evident throughout the bathroom including on the floor, toilet and side of the bathtub, 8. Plaintiff reasonably relied upon the statements and omissions of Defendants in agreeing to pay the cost of treatment. ‘The reliance of Plaintiff was reasonable in that he had no way of knowing of the falsity of the statements or omissions of Defendants and he was not placed on notice by Defendants that, in fact, their representations were not true. 9. Plaintiff would not have paid any of sums or entered into any agreement had he been informed of the facts as outlined above. 10. Asa proximate result of the actions of Defendants, Plaintiff paid $29,000.00 for ‘treatment of Lucas Compton. After paying this sum, Plaintiff was confronted by the chemical detoxification portion of the fraud and was enticed to pay another $6,500.00 for chemical detoxification, Total special damages arising from the conduct of Defendants is, therefore, not less than $36,500.00,10 u 12 13 14 15 16 17 18 19 20 21 2 23 24 25 11. In addition to the losses set forth above, Plaintiff claims that Defendants conduct rises to the level in which punitive damages are appropriate. The conduct of Defendants is pervasive and Plaintiff and his son are not the first victims of the conduct of Defendants. Defendants are engaged in a scheme or plan to enrich themselves and to provide a recruit base for the Church of Scientology rather than to provide competent treatment for chemical dependency. As such, their actions are intended to inflict harm upon the persons entering their programs while obtaining large sums of money for essentially worthless treatment. Such pattern of conduct has resulted in harm not just to Plaintiff and his son but many other families who have been traumatized by actions of Defendants. As a result, the conduct of Defendants falls within that type of conduct which is viewed as constituting a conscious disregard for the rights of others in general and Plaintiff in particular. As a result, punitive damages in the sum of $1,000,000.00 should be ordered. ‘Wherefore Plaintiff prays for judgment as set forth below: SECOND CAUSE OF ACTION [Breach of Contract] 12, Plaintiff hereby realleges paragraphs 1 through 10 of the first cause of action as if fully set forth herein. 13, In doing the things herein alleged the parties formed a contract. 14. The essential terms of the contract were that Defendants were to provide competent and reasonable treatment for chemical dependency to Plaintiff's son, Lucas Compton, in exchange for the payment of money by Plaintiff. 15, While the terms of the agreement were in writing, no actual written contract was signed by Plaintiff.10 u 12 14 15 16 17 18 19 20 oa 2 23 24 25 16. Plaintiff fulfilled all of the terms of the contract in that he has paid all sums demanded or requested of him. 17. Defendants are in material breach of the agreement by doing the things herein alleged. This breach includes the provision of substandard treatment, no treatment or treatment that is, in fact, harmful to the person undergoing treatment. 18. As a proximate result of the conduct of Defendants, Plaintiff has been damaged as alleged herein in the sum of $35,500.00 for payment of funds for which services were not provided. Wherefore, Plaintiff prays for judgment as set forth below: PRAYER FOR RELIEF Plaintiff hereby prays for relief as follows: 1. For general and special damages in an amount of $35,500. For punitive damages on the second cause of action in the amount of $1,000,000.00; . For cost of suit incurred herein. * }. For such other and further relief as the court may deem just. Dated: whslro P. HANNON II Attorney for Plaintiff: DAVID COMPTON